ASFPM Makes Recommendations for Strengthening CRS
On Sept. 9, ASFPM submitted comments in response to FEMA’s Request for Information to gather public feedback on ways the agency can improve the Community Rating System (CRS). ASFPM grouped its comments into four major themes:
- CRS’ Role in Comprehensive Flood Risk Management: ASFPM emphasized that CRS should not be viewed solely through the lens of insurance discounts. The CRS plays a broader role in supporting flood risk management by encouraging community-wide practices that reduce flood risk and support NFIP’s comprehensive goals. ASFPM cited studies demonstrating CRS’ success in reducing flood claims and noted we have received ample feedback from members suggesting that there is widespread support at the community level for the comprehensive approach CRS uses to promote flood risk reduction through various community-wide activities and elements.
- A Simpler CRS for Everybody: ASFPM advocated for a simplified CRS program that reduces administrative burdens, making it easier for more communities to participate. We suggested the possibility of auto-enrolling all NFIP communities into CRS, provided there is significant simplification of the enrollment process and administrative requirements.
- CRS Flexibility: ASFPM supports greater flexibility in how communities participate in CRS, including the question around allowing communities to exchange premium discounts for capacity building grants that could help fund floodplain management initiatives. Additionally, we recommended enabling regional participation models to help smaller or under-resourced communities engage in the CRS program.
- A Holistic Approach to CRS Technical Assistance: To support a simplified and flexible CRS, ASFPM called for a coordinated technical assistance program that includes robust support from state floodplain management offices, FEMA regional offices, and external contractors. The goal is to ensure consistent, timely support for all participating communities, and that includes better use of data and improved training opportunities.
“By implementing the CRS program in the way we’ve outlined in these comments, it can also be made far more equitable than it is today. By ensuring all communities have the ability to participate in a simpler, more flexible program where technical assistance is abundant, FEMA can ensure that all communities and policy holders can reap the rewards of CRS participation.”
